Privacy Policy

Effective Date: 12/19/2019

Last Updated: 12/19/2019

SourceLink, LLC, Path Interactive, and our affiliated entities (collectively, “we” or “us”) are committed to protecting and respecting consumer privacy and consumer privacy choices. We desire to comply with all applicable federal, state, and local laws and regulations and all prevailing industry ethical standards in the United States. This Privacy Policy covers our collection, use, and disclosure of personal information through: (a) our web sites www.sourcelink.com, www.pathinteractive.com, and all other sites owned or operated by us or our affiliate entities (collectively, the “Site”); and (b) our direct mail, digital marketing, and other marketing and related services (collectively, the “Services”). The use of information collected through our Services shall be limited to the purpose of providing the Services for which the client has engaged us and as otherwise noted below. We will share your personal information with third parties only in the ways that are described in this Privacy Policy.

Governing Law

You should be aware that data related to the Site and data related to the provision of our Services is hosted, processed, and handled in the United States. We comply with all applicable laws of the United States.

We recognize that the Site may be accessed from anywhere in the world, and that the laws of the jurisdictions in which some users are located may differ substantially from those of the United States and the State of Illinois. Because we cannot practicably prevent users in different jurisdictions from accessing the Site, you are responsible for knowing and complying with the laws of your jurisdiction. If such laws conflict with your use of the Site or any of its content or functionality, the Site is not intended for you, and we ask you not to use it or submit any information through it.

Information We Collect

We collect personal information in connection with marketing our Services to our clients and prospective clients. For example, when you contact us through our Site for information regarding our Services or when you access our information resources on our Site, we will collect personal information from you such as name, phone number, company, email address, IP address, and geographic location.

We also collect or otherwise obtain personal information in connection with providing Services to our clients. For example, our clients may provide personal information to us so that we can provide direct mail or digital marketing services. We also obtain personal information concerning consumers from third parties such as credit reporting agencies in connection with providing direct mail and/or digital marketing services to our clients. In connection with providing our Services to our clients, we collect personal information of individuals with whom we have no direct relationship.

In the last 12 months, we have collected the following categories of personal information from consumers:

Personal information does not include: publicly-available information from government records; de-identified or aggregated consumer information; health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) or the California Confidentiality of Medical Information Act; information covered by certain sector-specific privacy laws including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, or the California Financial Information Privacy Act.

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

Directly from you. For example, from forms you complete on our Site.

Indirectly from you. For example, from observing your actions on our Site and other web sites such as through the use of cookies (discussed further below).

From our clients. For example, our client may provide us with their email mailing list for us to append demographic information to the list.

From other third parties. For example, from credit reporting agencies or from other commercial information providers.

Our Use of Personal Information

We may use, sell, or disclose the personal information we collect via our Site for one or more of the following purposes:

To fulfill or meet the reason you provided the information.

To process your requests, purchases, transactions, and payments, and to prevent transactional fraud.

To provide support and respond to inquiries, including to investigate and address your concerns and monitor and improve our responses.

To help maintain the safety, security, and integrity of our Site, Services, databases, and other technology assets.

For testing, research, analysis, development, and refinement of our Services.

To comply with legal obligations. Though we make every reasonable effort to preserve user privacy, we may need to disclose personal information when required or requested by law and we have a good-faith belief that such action is necessary to pursue our legal rights or to comply with a current judicial proceeding, a court order, subpoena, government investigation, or legal process served on SourceLink, Path Interactive, or any of our affiliated entities. You agree to hold us harmless for such disclosure.

To evaluate or conduct business transactions. In the event we go through a business transition, such as a merger, acquisition, or sale of a portion of our assets, users’ personal information will, in most instances, be part of the assets transferred or sold as part of the transaction along with the other business assets sold or transferred.

We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.

We may use, sell, or disclose the personal information we obtain from our clients or from other third parties in connection with providing Services to our clients for one or more of the following purposes:

To provide our Services to our clients. For example, we may assist our clients with adding demographic information to their email lists, preparing targeted marketing communications based on consumer personal information, or developing analytics to target certain audiences for marketing purposes.

To deliver content and product offerings relevant to your interests including targeted offers and ads through our clients’ websites and other third party websites.

To provide support and respond to inquiries, including to investigate and address client concerns and monitor and improve our responses.

To help maintain the safety, security, and integrity of our Site, Services, databases, and other technology assets.

To comply with legal obligations. Though we make every reasonable effort to preserve our client’s consumer personal information, we may need to disclose personal information when required or requested by law and we have a good-faith belief that such action is necessary to pursue our legal rights or to comply with a current judicial proceeding, a court order, subpoena, government investigation, or legal process served on SourceLink, Path Interactive, or any of our affiliated entities. You agree to hold us harmless for such disclosure.

Disclosure or Sharing of Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep the personal information confidential and not use it for any purpose other than that described in the contract. We may use third party suppliers to provide ancillary services to fulfill client orders, manage email infrastructure to send emails on our behalf or our clients’ behalf, and a data center hosting provider to manage portions of our production IT infrastructure. When you engage us to provide our Services, any personal information provided to us is disclosed as necessary to the third party to provide that Service.

In the twelve (12) months preceding the effective date of this Privacy Policy, we have disclosed the following categories of personal information for a business purpose:

Cookies and Other Automated Data Collection Technologies

We collect information relating to your use of our Site through the use of various automated data collection technologies. If you visit our Site, we may collect various website navigation information and use tracking technologies such as cookies and web beacons to collect and store information from you. The information we may collect includes: standard information from your Internet browser (such as browser type and browser language), language choices, time zone, your Internet Protocol (IP) address, actions you take on our websites, URL and page metadata, access time, referring website, installation data (such as the operating system type and application version), and your search queries.

We may collect, use, and process usage data such as number of sessions, users, number of sessions, number of users, page views, number of page views per sessions, average session duration, bounce rate, percentage of new sessions, language of user, country, city, new versus returning users, browser type, operating system, internet service provider, IP address, screen resolution size, and mobile device brand. The usage data is collected and processed for the following purposes: (a) to maintain and improve the performance and integrity of our Site, (b) to understand which portions of our Site are most commonly deployed and preferred by customers and how customers interact with our Site, (c) to ensure that your visit to our Site is smooth, reliable and as useful to you as possible, (d) to serve content and more personalized advertising as relevant to you and your interests as possible.

We use both session ID cookies and persistent cookies. We use session cookies to make it easier for you to navigate our site. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “Help” menu option.

“Do Not Track” is a privacy setting that you may set in your web browser. If turned on, this setting requests that websites not track information about users. We honor “Do Not Track” browser settings or signals.

The use of cookies or other data collection technologies by our clients, tracking utility company, and service providers is not covered by our Privacy Policy. We do not have access or control over these cookies or technologies. Please review their respective privacy policies for more information about how your personal information may be collected and used.

Children’s Privacy

Protecting the privacy of the young is especially important. For that reason, we never collect or maintain information from those we actually know are under 16, and no part of our Site or our Service is designed or intended to attract anyone under 16. If you believe we have collected information concerning a children under 16, please contact us at privacy@sourcelink.com to let us know and, after reasonable confirmation, we will delete the child’s personal information.

Links

Our Site contains links to other web sites. Please be aware that we are not responsible for the privacy and other practices or activities of such other web sites. We encourage our users to be aware when they leave our Site and to read the privacy statements of each and every web site that collects personal information. This Privacy Policy applies solely to information collected by this Site.

International Transfer of Information

While SourceLink, Path Interactive, and our affiliates have globally reaching offerings of knowledge and product introductions, we only have employees and operations in the United States. We do not transfer or store personal information across international geographical borders, unless it is requested by our client, required for the provision of services, or requested by a governing authority.

Open Forum

Our Site may offer publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at privacy@sourcelink.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Security

This Site takes commercially reasonable precautions to protect personal information. We use commercially reasonable measures to ensure information submitted or collected via the Site is protected. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If users have any questions about the security of our Site, users can contact us at privacy@sourcelink.com.

We also take commercially reasonable measures to ensure personal information we receive from our clients or that we collect on behalf of our clients is protected. When clients provide us with their customer’s personal information, we apply commercially reasonable controls throughout the Internet gateway and production process utilizing information technology components and tools such as firewalls, encryption, and network monitoring to ensure client data is protected according to the standards required by their industry, and through formally communicated requirements.

Choice/Opt-out

We will send our clients strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our Services are temporarily suspended for maintenance, we might send clients an email. Generally, you may not opt-out of these communications, which are not promotional in nature.

If you no longer wish to receive promotional communications about our Services, you may opt-out of receiving these communications by contacting us via email at privacy@sourcelink.com. If your personal information changes, you may correct, update, or delete it by emailing us at privacy@sourcelink.com. We will respond to your request within 30 days. We will retain your information for as long as your account is active or as needed to provide you Services. We will retain and use your information as necessary to provide you with the requested Services and/or to comply with our legal obligations, resolve disputes, and enforce our agreements.

If you are a customer of our client and believe we have your personal information, please direct your request to our client (the data controller). Our client can ask us to remove or correct their customer’s data, and we will respond to their request within 30 days.

If you are a California resident, you may have additional or different rights, as described below.

Additional Rights for California Residents

The California Consumer Privacy Act (CCPA) provides consumers who are California residents with specific rights regarding their personal information. If you are a California resident, this section describes your CCPA rights and explains how to exercise those rights.

Right to Information. Subject to certain limits, California residents may ask us to provide them with the following information for the 12-month period preceding their request:

(1) The categories of personal information we collected about them;

(2) The categories of sources from which the personal information was collected;

(3) The business or commercial purpose for collecting personal information;

(4) The categories of third parties with whom we shared the personal information;

(5) The specific pieces of personal information we collected about them (also called a data portability request);

(6) If we disclosed personal information for a business purpose, a list of the disclosures for a business purposes and the personal information categories that each category of recipient received; and

(7) If we sold personal information for a business purpose, a list of the sales and the personal information categories that each category of recipient purchased.

Pursuant to a temporary exception in the CCPA, we do not provide these information and data portability rights for personal information reflected in business to business communications.

Right to Delete. Subject to certain exceptions, California residents also have the right to ask us to delete any personal information that we have collected about them, subject to certain limitations as set forth under CCPA.

To submit a request for information or a request to delete, California residents may contact us in any of the following ways:

To protect your privacy and security, we will also take reasonable steps to verify your identity before providing your personal information and before deleting your information. Only you or someone legally authorized to act on your behalf may make a verifiable request related to your personal information. If someone else is authorized to make a request on your behalf, they may submit a request using the form located here. We do not charge a fee to respond to your request unless it is repetitive (more than twice in a 12-month period) or excessive.

Pursuant to a temporary exception in the CCPA, we do not provide these deletion rights for personal information reflected in business to business communications.

Right to Opt Out of the Sale. The CCPA prohibits third parties who purchase personal information from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales. If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following site:

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales.

Right to Nondiscrimination. California residents also have the right to not be discriminated against if they exercise their privacy rights under California law. Unless permitted by the CCPA, we will not:

Deny you goods or services.

Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

Provide you a different level or quality of goods or services.

Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. We do not currently provide any financial incentives. We will update this information should that change at some point in the future.

Notification of Changes

If we decide to change our Privacy Policy, we will post changes to this Privacy Policy so our users are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If we make any material changes we may notify you by email (sent to the email address specified in your account) or by means of a notice on this Site of the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Information

If users have any questions or suggestions regarding our Privacy Policy, please contact us at: